Case Details

Citation(s)
2026 SLD 2555 = 2026 SHC 671
Sindh High Court
Special Customs Reference Application No.795 of 2024, Special Customs Reference Application No.796 of 2024, Special Customs Reference Application No.797 of 2024, Special Customs Reference Application No.798 of 2024, Special Customs Reference Application No.799 of 2024, Special Customs Reference Application No.800 of 2024, Special Customs Reference Application No.801 of 2024, Special Customs Reference Application No.802 of 2024, Special Customs Reference Application No.803 of 2024, Special Customs Reference Application No.804 of 2024, Special Customs Reference Application No.805 of 2024, Special Customs Reference Application No.806 of 2024, Special Customs Reference Application No.807 of 2024, Special Customs Reference Application No.808 of 2024, Special Customs Reference Application No.809 of 2024, Special Customs Reference Application No.814 of 2024, Special Customs Reference Application No.815 of 2024, Special Customs Reference Application No.816 of 2024, Special Customs Reference Application No.817 of 2024
Presented By: Mr. Muhammad Faisal Kamal Alam, J. Ms. Sana Akram Minhas, J.
Date of Hearing                      :           31.10.2025,     08.12.2025,16.12.2025     and 19.12.2025. Date of Decision                     :           30.03.2026. Applicant[s]                             :  M/s. Pak Suzuki Motors Company Limited, through Mr. Raashid Anwer, Advocate along with Yousuf Khalid Anwer, Advocate.
Respondent No.1                    :           The Collector, through Mr. Sardar Zafar Hussain, Advocate.
Respondents No.2 & 3            :           Nemo.

M/s. Pak Suzuki Motors Company Limited

VERSUS

The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others, M/s. Pak Suzuki Motors Company Limited versus The Collector and 2 others

Law: Customs Act, 1969

Section: 19, 32(1), 32(2), 79, 156(1), 196, 196(5), 209

Law: Customs Rules, 2001

Section: 101

Law: Sales Tax Act, 1990

Section: 3, 6, 33, 34

Law: Income Tax Ordinance, 2001

Section: 148

Summary The High Court decided multiple Special Customs Reference Applications through a common judgment concerning whether M/s. Pak Suzuki Motors Company Limited was liable to pay Additional Customs Duty (ACD) on imported CKD vehicle components, sub-components, assemblies, and sub-assemblies. The Customs Department claimed that the exemption under the relevant SROs applied only to complete CKD kits and not to individual components. Pak Suzuki argued that the WeBOC customs system required CKD kits to be declared in separate consignments, but the imported items collectively formed complete CKD kits used exclusively for manufacturing vehicles up to 1000cc. The Court held that the Customs Department had wrongly interpreted the SROs, failed to establish any misdeclaration, fraud, or misuse of the concessionary scheme, and ignored undisputed evidence and the Engineering Development Board's clarification. It ruled that the imported components were entitled to exemption from ACD, set aside the orders of the Customs authorities and Appellate Tribunal, and allowed all the Reference Applications. Sections Used Section 19 – Customs Act, 1969 Section 32(1) & (2) – Customs Act, 1969 Section 79 – Customs Act, 1969 Section 156(1) (Clause 14) – Customs Act, 1969 Section 196 Section 196(5) – Customs Act, 1969 Section 209 – Customs Act, 1969 Rule 101 – Customs Rules, 2001 Sections 3, 6, 33 & 34 – Sales Tax Act, 1990 Section 148 – Income Tax Ordinance, 2001 Sections (Numbers Only) 19, 32(1), 32(2), 79, 156(1), 196, 196(5), 209, 101, 3, 6, 33, 34, 148 Two 2-Word Descriptions Customs Exemption CKD Imports       J U D G M E N T Due to the commonality of facts and the identical question of law involved – namely, the admissibility of exemption from Additional Customs Duty on the import of sub-components, components, sub-assemblies, and assemblies under the relevant SROs – all these titled References are being decided through this common judgment. The Applicant-Company has challenged the Judgment of the learned Custom Appellate Tribunal and Order-in-Original [collectively referred as the…
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